Federal

  • July 27, 2023

    Tax Court Finds Man Received Life Insurance Distributions

    A man received constructive life insurance distributions totaling about $18,600 in 2017, the U.S. Tax Court ruled Thursday.

  • July 27, 2023

    US Chamber Calls For Changes To Minimum Tax Rule

    The treatment of nonrefundable, nontransferable U.S. tax credits under model rules for the 15% global minimum corporate tax should be renegotiated, the U.S. Chamber of Commerce told lawmakers in a letter.

  • July 27, 2023

    Wife Liable For Taxes In Husband's Biz Loss, 2nd Circ. Says

    A New York man and his wife are both responsible for $800,000 in taxes and penalties he incurred for failing to support a substantial loss deduction in a business he held an ownership interest in, the Second Circuit said Thursday.

  • July 27, 2023

    House Bill Seeks Federal Wealth Tax

    A federal tax tied to the median wealth of U.S. residents would be imposed on the ultra-wealthy under a bill introduced in the U.S. House of Representatives.

  • July 27, 2023

    Mylan's Litigation Costs Are Tax Deductible, 3rd Circ. Rules

    The Third Circuit on Thursday backed a finding that generic-drug maker Mylan was not on the hook for $50 million in taxes the Internal Revenue Service said it should pay over deducted patent litigation fees.

  • July 27, 2023

    Senate Bill Targets Tax Deductions For Defamation Payments

    A bill introduced in the U.S. Senate would prevent major corporations from taking income tax deductions for certain defamation-related payments.

  • July 27, 2023

    Feds Say Man Who Jilted Payroll Tax Lied To Get PPP Loan

    Just days after a Sixth Circuit panel said a mistrial was justified in a tax case because the judge was exposed to COVID-19, federal prosecutors said a business owner on trial for allegedly failing to remit payroll taxes lied to the government to obtain pandemic relief loans by saying he wasn't subject to an active indictment.

  • July 27, 2023

    IRS Seeks Comments On Alternative Resolution Programs

    The Internal Revenue Service asked for comments Thursday on how to improve its alternative programs for resolving tax disputes.

  • July 26, 2023

    IRS Urged To Widen 'Semiconductor' Term In Chips Tax Credit

    Manufacturers and their industry representatives urged IRS officials Wednesday to broaden the definition of "semiconductor" in forthcoming final rules for the 25% advanced manufacturing investment tax credit so more downstream producers in the chip supply chain can qualify for the incentive.

  • July 26, 2023

    IRS Boosting Employee Credit Compliance Work, Werfel Says

    With a rising number of dubious claims for the employee retention credit continuing to come in, the Internal Revenue Service is stepping up its compliance work in that area, agency Commissioner Daniel Werfel said.

  • July 26, 2023

    Settlement OK'd Over Former Pot Co. Exec's $1.2M Tax Bill

    A New York federal judge approved a settlement between a cannabis company and a former executive who claimed he was illegally reclassified as an independent contractor, leaving him with $1.2 million in tax liabilities, according to an order.

  • July 26, 2023

    Dems Probe Defense Firms On Research Tax Cut 'Giveaway'

    Democratic lawmakers have pressed four major defense contractors to explain how the companies would benefit from the restoration of a research-related tax deduction they have "aggressively" lobbied for, arguing that the proposed reinstatement is a "giveaway" to large companies.

  • July 26, 2023

    Man Owes Tax On $572K In Damages, Tax Court Says

    A man owes taxes on $572,000 in damages he received for claims that he was the victim of age discrimination and was wrongfully let go from his job, the U.S. Tax Court said Wednesday.

  • July 26, 2023

    Tax Tipster In $60M Case To Appeal Award Denial To High Court

    A whistleblower whose information led the IRS to discover an improper $60 million deduction urged the D.C. Circuit to halt enforcement of its decision denying his award, saying he plans to appeal to the U.S. Supreme Court.

  • July 26, 2023

    Wyden Unveils Bills To Strip PGA Of Tax-Exempt Status

    PGA Tour Inc. and other sports organizations with assets exceeding $500 million would lose their tax-exempt status under legislation introduced Wednesday by Senate Finance Committee Chairman Ron Wyden.

  • July 26, 2023

    1st Circ. Mulls IP Transfer In Timberland's $1.45B Tax Row

    A panel of First Circuit judges signaled concern that allowing the value of intangibles acquired in a corporate reorganization by the parent company of Timberland to be taxed annually could lead to more transfers where disposition of stock doesn't trigger a lump-sum tax payment.

  • July 26, 2023

    Final COVID Employment Credit Recovery Rules Published

    The Internal Revenue Service's final rules for recapturing erroneous coronavirus employment tax credits were published Wednesday in the Federal Register.

  • July 26, 2023

    IRS Releases Fast-Track Program For Letter Rulings

    The Internal Revenue Service detailed a program Wednesday for fast-tracking letter ruling requests primarily under the jurisdiction of the associate chief counsel who handles corporate matters, supplanting a pilot program.

  • July 26, 2023

    Couple Ask 7th Circ. For Do-Over In $500K Levy Challenge

    A couple asked the Seventh Circuit to reconsider its decision allowing the Internal Revenue Service to proceed with a levy to collect $500,000 they owe for the husband's interests in oil and gas partnerships, court documents show.

  • July 26, 2023

    Pension Plan Segment Rates Increase In July

    Segment rates for calculating pension plan funding rose in July, the Internal Revenue Service said Tuesday.

  • July 26, 2023

    These Firms Have The Most Diverse Equity Partnerships

    Law firms have made only modest progress in moving the needle on diversity, particularly at the equity partnership level. Still, a few are setting a new standard and actively increasing their representation of attorneys of color.

  • July 26, 2023

    6th Circ. Judges Skeptical Of Tax Suit Over Staked Crypto

    The Sixth Circuit seemed skeptical of a couple's tax refund suit that also seeks to block the IRS from taxing cryptocurrency they've earned through staking, with one judge saying Wednesday he's "struggling with what the problem" is for the couple given that the agency refunded their taxes.

  • July 26, 2023

    Hunter Biden's Plea Deal Collapses In Federal Court

    A Delaware federal judge balked Wednesday at approving presidential son Hunter Biden's guilty plea to federal tax and weapons offenses, declaring that the U.S. attorney's office and Biden's defense failed to explain or justify the court's role in approving or enforcing its terms.

  • July 26, 2023

    Couple Seek Refund Of $2M In Offshore Reporting Penalties

    A formerly married couple from Pennsylvania sought a refund of about $2 million in penalties they paid to the IRS regarding filing requirements for an offshore trust, telling a federal court that they shouldn't have been assessed any of them.

  • July 26, 2023

    IRS Had 1.8K Incorrect Collection Periods In 2022, TIGTA Says

    About 1,800 accounts for taxpayers with collections due process cases had an incorrectly narrow window for collecting late taxes in 2022, the Treasury Inspector General for Tax Administration estimated in a report released Wednesday.

Expert Analysis

  • Why S Corporation Payments Are Almost Always Wages

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    The recent U.S. Tax Court ruling in Lateesa Ward v. Commissioner has employment and income tax lessons about why payments from an S corporation to its sole shareholder are wages and not distributions of profit in most cases, says Bryan Camp at Texas Tech University School of Law.

  • 3 Arthrex-Adjacent High Court Cases Could Affect PTAB's Fate

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    As patent practitioners await a decision on the constitutionality of Patent Trial and Appeal Board judges in U.S. v. Arthrex, they should keep their eyes on three other pending U.S. Supreme Court cases that, while not IP-related, involve overlapping legal issues, including the severability doctrine, says William Milliken at Sterne Kessler.

  • Surveying Global Tax Updates For Sovereign Wealth Investors

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    As the market transitions to a post-pandemic phase, sovereign wealth fund and other foreign institutional investors must evaluate how recent U.S., EU and U.K. tax changes may affect their private fund investments, say attorneys at Morgan Lewis.

  • Offshore Wind Push Is Good News For NYC Building Owners

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    With a surge of federal and state support for offshore wind power in New York state, the projects now in development should greatly benefit New York City building owners seeking to comply with the city's Climate Mobilization Act, says Raymond Pomeroy at Stroock.

  • Coke, 3M Tax Cases May Not Settle Blocked Income Debate

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    Even if the challenged U.S. Department of the Treasury regulation on blocked income is struck down by the U.S. Tax Court in the pending Coca-Cola and 3M cases, the obligations of a taxpayer that had, but failed to avail itself of, alternative means to secure payment will remain an open question, say Matthew Frank and Amanda Varma at Steptoe & Johnson.

  • OCC Rule Misaligned With Some Tax Equity Safe Harbors

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    The Office of the Comptroller of the Currency's recently finalized rule on national banks' participation in tax equity financings aligns with safe harbor guidance for renewable energy investments, but not with safe harbor structures for historic preservation and carbon capture tax credits, say attorneys at Nixon Peabody.

  • IRS Should Level The Field For R&D Tax Credits

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    A recent increase in denials of research and development tax credits to small businesses in the architectural, engineering and construction community shows the Internal Revenue Service should issue new guidance to ensure a fair playing field and an opportunity to continue innovating in the U.S., says Julio Gonzalez at Engineered Tax Services.

  • IRS Should Revise Private Debt Collection Methodology

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    To fulfill the congressional intent underlying the Taxpayer First Act, which aims to protect delinquent taxpayers from entering into payment plans they cannot afford, the Internal Revenue Service should use both last-return-filed and third-party income information in its methodology for identifying low-income taxpayers, says National Taxpayer Advocate Erin Collins.

  • Applying OECD Guidance On COVID-19 Transfer Pricing

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    In light of the recently released Organization for Economic Cooperation and Development's guidance on the transfer pricing implications of the pandemic, taxpayers should be prepared to explain and defend their transfer pricing decisions for fiscal year 2020 for contemporaneous documentation and in future tax audits, say Susan Fickling and TJ Michaelson at Duff & Phelps.

  • A Tough Road Ahead for Democrats' Ambitious Policy Agenda

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    While Democrats in Congress are well on their way to enacting an initial COVID-19 relief bill, they will face challenges when pivoting to President Joe Biden's Build Back Better goals for job creation and economic revitalization, say Russell Sullivan and Radha Mohan at Brownstein Hyatt.

  • Coca-Cola Tax Ruling Offers 5 Lessons For Multinationals

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    The U.S. Tax Court's decision that Coca-Cola owes more than $3.3 billion in taxes is instructive on important transfer pricing concepts, including those regarding intercompany agreements, the arm's-length standard and tax certainty, says ​​​​​​​Justin Radziewicz at Duff & Phelps.

  • Small Biz Should Self-Advocate For Tax Relief Under Biden

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    Small and medium-sized businesses have significant potential for achieving regulatory relief from the U.S. Department of the Treasury and other federal agencies during the Biden administration, but to do so they must define their priorities, leverage two federal statutes that require the Treasury to protect them and make their voices heard through communal e-advocacy, says Monte Silver at Silver & Co.

  • SD Ruling Threatens Marijuana Legalization Momentum

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    A South Dakota state court decision in Thom v. Barnett, invalidating a state constitutional amendment legalizing recreational marijuana, serves as a reminder that legalization efforts at any level could meet some resistance, says David Standa at Locke Lord.

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